JBK Unmanned Systems

8 Sentinel Trail Palm Coast, Fl 32164

386.559.4831 jbkunmannedsystems@gmail.com

May 26 th , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave ., SE Washington, DC 20590

Re: Request for Exemption per PL 112

- 95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

JBK Unmanned Systems respectfully requests an exemption of the above applicable sections of title 14 CFR for the purpose of conducting commercial operation s including, but not limited to, aerial p hotography, v ideography, survey and mapping , inspections as well as providing services for search and rescue/recovery and firefighting operations

. JBK will use its small Unmanned Aircraft System(sUAS) within controlled access airspace, using licensed airmen,

and will employ a comprehensive safety, training, and planning program. The employment of sUAS platforms for these missions should provide the FAA with good cause to find that these operations enhance safety by eliminating the need

to use conventional aircraft in t he someti mes unique environments where a sUAS would be particularly adept, but a conventional aircraft may pose a hazard

to its crew and those on the ground.JBK Unmanned Systems requests exemption from the following applicable

regulations, purs uant to the Administrator’s authority to grant exemptions contained in 49 U.S.C. § 106(f), 40113, and 44701:

14 CFR 21 Part H

- Airworthiness Certificates, 14 CFR 61.113(a) and (b)

– Pilot in Command

, 14 CFR 91.103

– Preflight action,

14 CFR 91.105

– Fligh t crewmembers at stations,

14 CFR 91.109

– Flight instructions

, 14 CFR 91.119

- Minimum Safe Altitudes

, 14 CFR 91.121

- Altimeter settings

, 14 CFR 91.151(a)

- Fuel requirements

, 14 CFR 91.405(a)

- Maintenance required

, 14 CFR 91.407(a)(1)

- Operations afte r maintenance

, 14 CFR 91.409(a)(2)

- Inspections

, 14 CFR 91.417(a) and (b)

– Maintenance records

OPERATION S OVERVIEW

Our operations utilize sUAS in a manner that provides services not offered by manned aircraft or enhances the level of safety at which th e tasks can be completed in manned aircraft

. Examples of the proposed aerial photography

oper ations include real estate

, insurance damage assessment and various inspection services. These types of operations restrict the use of the sUAS to a small area typ ically encompassing a limited number of residential and

commercial properties at a time. The areas in which the flight takes place can readily be protected with secured access

. The structu res on these properties provide sufficient protection from the sUAS and can be completed with much less

risk than that of a manned operation at low altitudes.

JBK’s survey, mapping and inspection operation s will include mapping and inspections of both agriculture and construction sites utilizing a sUAS rotorcraft flying p re

- programmed grids that can be interrupted and returned to a safe landing zon e. Currently these operations are executed by general aviation

aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes

and spee ds. Our operation would greatly inc rease the level of safety, replacing large aircraft with a sUAS under 35 pounds and restricted to speeds no greater

than 50 knots. These sites are areas that can readily be secured by JBK personnel and would not provide any additional risk to th e general public.

JBK Unmanned Systems will offer services to local public safety agencies where FAA rules and local laws perm it. These services could include search and rescue of missing persons, evidence search, structural and wildland firefighting

oper ations and other operations where permitted.Any operations under this exemption would be conducted in accordance with the

strict parameters specified in the confidential Flight Operations Manual and confidential Pilot Operating Handbooks.

The limitation s and co nditions that JBK Unmanned Systems agrees to be bound

to include:

1. The sUAS will weigh less than 35 lbs. 2. Flights w ill be operated within VLOS of a pilot and/or observer and will be conducted during daylight hours only.

3. Flights will be term inated at 25% battery power reserve. 4. Flights will be operated at an altitu de of no more than 400 feet AGL and ground speed will not exceed 50 knots. 5. Preflight inspections of all components of the system and a safety risk

assessment will be conducted and a separate log/checklist will be filed for each flight.

6 . Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer and based on results of the safety assessment may include a security

coordinator . A sensor operator may also be used when necessary.

7 . Observer and pilot will at all times be able to communicate by voice

. 8 . Pilot and observer will be trained in the operation of the UAS to be used and will receive up

- to

- date information on the particular UAS to be operated as

re quired in the Flight Operations Manual (FOM will be provided upon request).

9 . sUAS pilot will be an FAA license d airman with at least a sport pilot

cer tificate and drivers license as required in the current FAA policy.

10 . The UAS will only operate within a confined “ Safety Perimeter ” as defined in

the FOM

. 11 . A briefing will be conducted in regard to the planned sUAS operations prior to each day’ s activities. It will be mandatory that all personnel who will be performing duties within the boundaries of t he safety perimeter be present for this briefing.

12 . Written and/or oral permission from the relevant property holders will be

obtained.

13 . All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, inclu ding local law enforcement, fire, or other appropriate governmental agencies.

14 . If the sUAS loses communications or loses its GPS signal, the UAS will have

the capability to return to a pre

- determi ned location within the Safety Perimeter

and land.AIRCRAFT TO BE UTILIZED

JBK Unmanned Systems will utilize a DJI Insp ire 1 and DJI Phantom 3 for its operations. The sUAS are rotocopter configuration and will weigh no more than 35 pounds. They will operate no faster than 50 knots groundspeed. The aircra ft are agile, having the ability to hover, and move about its three axes simultaneously. The aircraft will be operated below 400 feet Above Ground Level (AGL) and continuously within the Pilot in Command’s (PIC) line of sight, so as to

not create a hazard to users of the national airspace system or public.

The above aircraft are equipped with the following safety features:

1) Both units have a “Return to Home” feature that is automatically activated when controller signal is lost and can be activated manual ly when problems occur or a preset battery level indicator is activated. 2) Both units have GPS capability that provides stability and allows the PIC

more control in various conditions. 3) Both units have programming such as “No Fly Zone” (preprogrammed no fly z ones around certain airports) and “Flight Limitations” that provide the ability to manually program height and distance limitations to meet FAA

rules. 4) The Inspire 1 has dual controllers so the camera can be controlled by a second operator , thus allowing th e PIC complete concentration on flight operations only. 5) The Phantom 3 has a “Waypoint System” allowing preprogrammed flight operations in certain circumstance.

Because of the sUAS’ specifications and flight characteristics, it poses no threat

to national security.

FLIGHT CREW

All of JBK Unmanned Systems operations will be performed by FAA licensed pilots with trained Visual Observers and, where necessa ry, Site Security Coordinators. These operations will be in controlled and secured environments

and onl y after a safety assessment has been completed. Prior to flight, the PIC and Visual Observer (VO) will complete the qualification process as outlined in

the company’s FOM. The Pilot in Charge will possess, at a minimum, a sport pilot’s certificate, meet ap plicable recent flight experience requirements and hold

a state driver’s license . The Visual Observer will be trained in accordance with the company’s FOM

.PREFLIGHT ACTION

In accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather briefing, survey the launch and recovery environments and review takeoff and landing distances and other applicable aircraft performance data, check the

aircraft and ground station/transmitter battery levels, and brief the Visual Observer (VO) and any othe r supporting crew on the mission, safety, and contingencies. All flights will be conducted in Day VMC conditions. Minimum flight crew shall include the PIC, Visual Observer to assist with seeing

- and

avoiding other aircraft, a Site Security Coordinator as d etermined by preflight risk analysis.

FUEL REQUIREMENTS

All JBK Unmanned Systems PICs will terminate flights when remaining battery power level reaches 25%.

sUAS MAINTENANCE

JBK Unmanned Systems will conduct all maintenance on the sUAS in

accordance wi th the FOM, POH and Manufacturer user manuals. All maintenance will be conducted by trained JBK Unmanne d Systems personnel. Repairs will be conducted by same or authorized manufacturer representative and will require a test flight after completion. Mainten ance, repair and software update logs will be strictly maintained and available for inspection by the proper

authorities.

FLIGHT SAFETY AND SECURITY

Because of the relatively small operating perimeter, any mechanical issues that may arise during a flight could be quickly mitigated by terminating the flight. Security of flight operations will follow procedures outlined in earlier sections. FOM and POH include sections on limitations of safe operations as well as emergency and abnormal operating procedures. Requirements for basic training and continuing education have been established.

Several principals of JBK Unmanned are current or former law enforcement and/or fire service personnel, including FEMA and USAR operations. Safety and security of all flights is of the utmost importance to JBK. The safety and security of flight operation s personnel and the public will not be adversely affected during

these activities.PUBLIC BENEFIT

Use of sUAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods:

1) Reduces statistical risk to human life due to manned aircraft accidents

or due to other dangerous activities that can be avoided. 2) Reduces the cost of obtaining such information, which benefits

co nsumers and the economy. 3) Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft.

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capab ilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justi fication to grant JBK Un manned Systems requested exempt ion, allowing for JBK Unmanned Systems c ommercial

ope rations for the purpose of photography, videography, inspections and survey pursuant to the company’s FOM and POH. Confidential Manuals are available on
request.

Sincerely,

James P. Gilbert Jr.

President

, JBK Unmanned Systems